FDA Voices (2026): MoCRA implementation progress — treat as a status board
FDA’s May 2026 Voices post walks listing, PFAS report, and leftover rulemakings. Useful as a checklist against the MoCRA statute page.
Guidance
SCCS opinion watch: how SMEs should triage ingredient news without panicking
An SCCS opinion is scientific advice to the Commission. It is not an annex amendment. Triage: listed in CosIng annex already, or still only an opinion?
EU Commission fragrance-allergen topic page: use it with 2023/1545, not instead of it
The Commission’s allergen topic page is context. The binding table is Annex III as amended by 2023/1545.
ASEAN Cosmetic Directive: shared annexes, national notification — 2025–26 still works that way
ACSB annex updates only become “your problem” when a Member State issues a circular. Budget ten front doors, not one ASEAN certificate.
FDA PFAS-in-cosmetics report (29 Dec 2025): data gap, not a federal ban
FDA’s MoCRA-mandated PFAS report found evidence too thin for safety determinations on most intentionally added PFAS. State bans can still apply.
China cosmetics GMP lift plan (2026–2028): expect more on-site questions, not a new ISO number
NMPA told provincial regulators to run a three-year quality-system improvement action. Manufacturers in China should expect deeper file-vs-floor checks.
US professional-use cosmetics: MoCRA labeling expectations still apply
“Salon only” is not a MoCRA off-ramp. Adverse-event contact and other required statements still need a home on the pack or the mandated alternative.
China NMPA reform opinions (17 Nov 2025): a 2030 roadmap, not a filing instruction
NMPA’s 24-measure reform opinion sets a 2030 destination. Use it to understand why 2026 announcements exist — do not file against a white paper.
EU CPNP and Responsible Person: the unglamorous duties that still stop first shipments
Article 4 and Article 13 duties did not change in 2025. They still cause more failed first shipments than annex chemistry.
MoCRA leftover rules (GMP, fragrance allergens, asbestos method): still a calendar, not a code
Statutory target dates for some MoCRA rules have slipped. Track FDA’s MoCRA page. Do not implement a draft you cannot cite.